What tolerance is there for TIL errors? If a mortgage loan has already closed, and the bank made an error and underdisclosed PMI, can we redisclose and correct the payment, or should we bite the bullet and self-insure for the difference?
Is it common for banks to put PMI on construction loans? We are looking at this but are having a hard time with the disclosures such as the "PMI cancel" notice.
When you renew a loan with now new funds, but there is PMI, is a rescission notice required?
Is there a compliance issue if you make an exception to your fixedrate home equity policy in order to extend the loan to value ratio from 80% 95% for one customer?
Each year the Federal Reserve Board updates the Official Staff Commentary to Regulation Z, Truth in Lending.
The Federal Reserve Board staff has held constant and issued a proposed update to Regulation Z's Official Staff Commentary in time for the holiday mail.
Our bank is introducing a new Home Equity Line of Credit loan service. We are considering mortgage lending protection insurance for each line, and wish to pass the premium on to the borrower/s. This would benefit the borrower/s as title policies or certificates would not be required. How should this cost be disclosed under Reg. Z and RESPA?
If we make a mortgage loan that we are going to hold and service and the loan to value is in excess of 80%, are there any regulations that require us to cover that loan with private mortgage insurance? Or is that simply a bank policy issue that goes to loan quality?
Without violating Truth in Lending, can a bank add mortgage insurance to a note. Does it matter if interest accrues on this amount.